COMPANY POLICY WITH RESPECT TO PERSONAL DATA PROCESSING

GENERAL PROVISIONS

The policy for the processing of personal data (hereinafter referred to as the Policy) was developed in accordance with the Federal Law of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter - FZ-152).

This Policy determines the procedure for the processing of personal data and measures to ensure the security of personal data in LLC OLD QUARTERS (hereinafter referred to as the Operator) in order to protect the rights and freedoms of a person and citizen when processing their personal data, including the protection of privacy rights, personal and family secrets.

The Policy uses the following basic concepts:

automated processing of personal data - processing of personal data using computer equipment;
personal data blocking - temporary suspension of personal data processing (unless it is necessary to process personal data);
personal data information system - a set of personal data contained in databases, and information technologies and technical means ensuring their processing;
de-identification of personal data - actions, as a result of which it is impossible to determine without the use of additional information that the personal data belong to a specific personal data subject;
personal data processing - any action (operation) or a set of actions (operations) performed with the use of automation tools or without using such tools with personal data, including the collection, recording, systematization, accumulation, storage, refinement (update, change), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
Operator - a state body, municipal body, legal or natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
personal data - any information relating to a directly or indirectly determined or determined individual (subject of personal data);
provision of personal data - actions aimed at disclosing personal data to a specific person or a certain circle of persons;
distribution of personal data - actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or to get acquainted with personal data of an unlimited number of persons, including public disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in some other way;
cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign natural or foreign legal entity;
destruction of personal data - actions, as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which the material carriers of personal data are destroyed.

The company is obliged to publish or otherwise provide unrestricted access to this Policy for the processing of personal data in accordance with Part 2 of Art. 18.1. FZ-152.


2. PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING

2.1. Principles of personal data processing

The processing of personal data by the Operator is carried out on the basis of the following principles:

- legality and fair basis;
- restrictions on the processing of personal data to the achievement of specific, predetermined and legitimate goals;
- to prevent the processing of personal data that is incompatible with the purposes of collecting personal data;
- prevent the merging of databases containing personal data that are processed for purposes that are incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
- Compliance of the content and volume of processed personal data with the stated processing objectives;
- prevent processing of personal data, redundant in relation to the stated objectives of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
- destruction or depersonalization of personal data on achieving the goals of their processing or in case of loss of the need to achieve these goals, if it is impossible for the Operator to correct the violations of personal data, unless otherwise provided by federal law.

2.2. Personal data processing conditions

The operator processes personal data in the presence of at least one of the following conditions:

- the processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
- the processing of personal data is necessary to achieve the goals stipulated by the international treaty of the Russian Federation or the law for the implementation and fulfillment of the functions, powers and duties imposed by the legislation of the Russian Federation;
- the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
- processing of personal data is necessary for the execution of the contract, the party to which either the beneficiary or the guarantor for which is the subject of personal data, as well as for the conclusion of the contract initiated by the subject of personal data or the contract for which the subject of personal data will be the beneficiary or surety;
- processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
- processing of personal data is carried out, access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data);
- processing of personal data to be published or mandatory disclosure in accordance with federal law.

2.3. Privacy Policy

The operator and other persons who have obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

2.4. Generally accessible sources of personal data

For the purpose of information support, the Operator may create publicly accessible sources of personal data of the subjects, including reference books and address books. Publicly available sources of personal data with the written consent of the subject may include his last name, first name, middle name, date and place of birth, position, contact telephone numbers, e-mail address and other personal data provided by the subject of personal data.
Information about the subject should be at any time excluded from publicly available sources of personal data at the request of the subject or by a court or other authorized government bodies.

2.5. Special categories of personal data

The processing by the Operator of special categories of personal data relating to racial, nationality, political views, religious or philosophical beliefs, health status, intimate life, is allowed in cases where:
- the subject of personal data has agreed in writing to the processing of his personal data;
- personal data is made publicly accessible by the subject of personal data;
- the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, legislation of the Russian Federation on pensions for state pensions, on labor pensions;
- the processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of other persons and obtaining the consent of the subject of personal data is impossible;
- the processing of personal data is carried out for medical and preventive purposes, in order to establish a medical diagnosis, the provision of medical and medical-social services, provided that the processing of personal data is carried out by a person professionally engaged in medical activities and obligated in accordance with the legislation of the Russian Federation to keep medical secrecy;
- the processing of personal data is necessary to establish or exercise the rights of the subject of personal data or third parties, as well as in connection with the administration of justice;
- the processing of personal data is carried out in accordance with the legislation on mandatory types of insurance, with insurance legislation.

The processing of special categories of personal data must be immediately terminated if the reasons for processing them are eliminated, unless otherwise provided by federal law.

The processing of personal data on criminal record may be carried out by the Operator only in cases and in the manner determined in accordance with federal laws.

2.6. Biometric personal data

Information that characterizes the physiological and biological characteristics of a person, on the basis of which his identity can be established - biometric personal data - can be processed by the Operator only with the consent in writing of the subject.

2.7. Assignment of personal data processing to another person

The operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by federal law, on the basis of an agreement with this person. The person who processes personal data on behalf of the Operator is obliged to comply with the principles and rules of personal data processing provided for by the Federal Law 152.


2.8. Cross-border transfer of personal data

The operator is obliged to ensure that the foreign state into whose territory it is supposed to transfer personal data ensures adequate protection of the rights of the subjects of personal data before such transfer begins.

Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:

- the consent in writing of the subject of personal data on the cross-border transfer of his personal data;
- execution of the contract to which the subject of personal data is party.



3. RIGHTS OF THE SUBJECT OF PERSONAL DATA

3.1. Consent of the subject of personal data to the processing of his personal data

The subject of personal data decides on the provision of his personal data and agrees to their processing freely, by his own will and in his interest. Consent to the processing of personal data may be given by the subject of personal data or his representative in any form allowing to confirm the fact of his receipt, unless otherwise established by federal law.

The obligation to provide evidence of the consent of the subject of personal data to the processing of his personal data or proof of the grounds specified in the Federal Law-152 is imposed on the Operator.

3.2. Rights of the subject of personal data

The personal data subject has the right to receive information from the Operator regarding the processing of his personal data, if such a right is not limited in accordance with federal laws. The personal data subject has the right to require the Operator to clarify his personal data, to block or destroy it if personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take measures provided by law to protect their rights .

The processing of personal data in order to promote goods, works, services on the market by making direct contacts with a potential consumer using means of communication, as well as for political campaigning, is allowed only with the prior consent of the subject of personal data. This processing of personal data shall be deemed to be carried out without the prior consent of the subject of personal data, unless the Company proves that such consent was obtained.

The operator is obliged to immediately stop, at the request of the subject of personal data, the processing of his personal data for the above purposes.
It is forbidden to make decisions based solely on automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, except in cases provided for by federal laws, or if there is agreement in writing to the subject of personal data.

If the subject of personal data considers that the Operator is processing its personal data in violation of the requirements of FZ-152 or otherwise violates its rights and freedoms, the subject of personal data has the right to appeal against the Operator’s actions or omissions to the Authorized Body to protect the rights of personal data subjects or in court .

The subject of personal data has the right to protect their rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in a court of law.

4. ENSURING PERSONAL DATA SECURITY

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of federal legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

- the appointment of officials responsible for organizing the processing and protection of personal data;
- limiting the number of persons who have access to personal data;
- familiarization of subjects with the requirements of federal legislation and regulatory documents of the Operator on the processing and protection of personal data;
- organization of accounting, storage and circulation of information carriers;
- identification of threats to the security of personal data during their processing, the formation of threat models on their basis;
- development of a personal data protection system based on the threat model;
- verification of the readiness and effectiveness of the use of information security tools;
- delimitation of user access to information resources and software and hardware for information processing;
- registration and recording of actions of users of personal data information systems;
- the use of antivirus and personal data protection system recovery tools;
- the use of firewalling, intrusion detection, security analysis and cryptographic information protection tools where necessary;
- organization of access control to the territory of the Operator, protection of premises with technical means for processing personal data.


5. FINAL PROVISIONS

Other rights and obligations of the Operator, as the operator of personal data are determined by the legislation of the Russian Federation in the field of personal data.

Operator officials who are guilty of violating the rules governing the processing and protection of personal data bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by federal laws.


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